Appendix G : comment Input and Forest Service Responses

Transcription

1 Appendix G: Comment period Input and Forest Service Response G - 1

2 1.1 Comment: 1. Dick Artley Wildlife and Recreation are never Secondary Issues with any ground disturbing project. On pages 15 and 16 the EA identifies 8 non key, other and secondary issues that should be dismissed.... Why did you choose to backhand the American public by placing the following resources in your unimportant resources list: plants, wildlife, recreation, scenic qualities, aquatics, fuels, soil, non-native invasive species (NNIS), economics, tribal gathering and traditional uses. Competent Rangers across America depend on the Chapter 3 effects to these resources to adjust the Proposed Action to minimize the adverse effects and still meet the P&N as much as possible. From my 31 years with the USFS I learned that most of these issues are the most issues to the public who use the national forests. The recreating public values, fish, wildlife, recreational opportunities and scenery more than anything else in their forests. Regardless of project type, these issues are not secondary issues. The project impacts might be minimal but this does not make them secondary issues. Regardless of project type, these issues must never be dismissed. Request for changes to be made to the final NEPA document: Scrap this inadequate pre-decisional EA. The next one will treat resources the so-called Secondary Issues section with respect and care. The next EA will omit the section on Other and Secondary Issues. 1.1 Response: We define the terms key and secondary issues in sections 1.8 and 1.9 of the EA and explain how they are used in the project development and disclosure of effects. Our intent was to explain to the reader that although there were no issues that resulted in development of another alternative, we recognize that there may be effects on the resources that are listed. Whether or not you agree with our approach and use of terms, we do agree with you that the important aspect is that the effects of this project on our resources. Plants, wildlife, recreation and the other resources that you and other members of the public are interested in are considered and adequately addressed in Chapter 3. In that regard we have met the intent of NEPA. Changing the label from secondary to something else would not result in different effects of the proposed activities on any of the resources listed. 1.2 Comment: quest for volume caused you to ignore and reject an effective biological Emerald Ash Borer treatment alternative Under your proposal, the trees will either die because of chainsaw or Emerald Ash Borer damage. Logging the trees will not stop the insect. The insects will just fly farther to reach healthy ash trees. This is clearly an attempt to remove the trees to help meet your annual cut expectation. You know you will simultaneously inflict logging and road construction damage resulting from building 12 miles of new G - 2

3 road and logging 6.2 square miles. Obviously, to you and your IDT members this is acceptable. Once again, you are all clueless. Read Opposing Views Attachments #1 and #4 to educate yourselves. Freshman forestry students learn this in college. A quick search of the web reveals the following 6 documents describe stingless wasp/ Emerald Ash Borer interaction (EAB). The USDA is publicizing the success of the research they are doing to perfect this type of EAB control. Apparently, the Chippewa NF is not part of the USDA. Can you guess why I m not happy that my tax dollars are being used to pay the salary for you and the IDT members? Do you regularly depend on the public to suggest how you should do your job? Request for changes to be made to the final NEPA document: Analyze a new alternative in detail that addresses the EAB with stingless wasps only. There would be no logging or road construction. 1.2 Response: The intent of this project is to maintain lowland hardwood forest and preserve hydrologic function on these stands through diversifying them to species that are not susceptible to EAB. To achieve this, one technique we will use is a timber harvest in 1/4-3/4 acre openings with harvesting individual trees between those openings. The gaps will occupy no more than 20% of the stand and the harvesting between the gaps will maintain a forested appearance. The reason we choose to predominantly use this technique is because it will allow more light to reach the forest floor and allow the species we plant to become established quicker. While the volume of trees removed from this project will count toward our annual timber harvest goal, that goal is not a driver for this project The following comments from your web search point out that stingless wasps are not the only answer to managing ash in light of EAB. Also all introductions of the wasps were in areas where there was the EAB available for the wasps to predate on. According to USDA Animal and Plant Health Inspection Service, it is premature to talk about the wasps effect on EAB populations Stingless wasps will not eradicate EAB. According to the MN Department of Agriculture, it has taken 3 years to find wasps a half mile from the nearest release site. In addition, proof of reproduction is only the first step to figuring out if, how and where the wasps can be a deterrent, Chandler said. Introducing the wasps to a site can be expensive: The one-eighth-inch tiny black bugs cost $4 apiece. Then tracking them and their larvae is extremely difficult. It required cutting down an infested tree and peeling back the bark in areas where ash borers leave their distinctive tunnels. Nor is it clear how well either insect will tolerate Minnesota s cold winters. Chandler said scientists believe that, like their prey, the wasps will do fine in southern Minnesota, but probably not far north in the state. G - 3

4 According to the London Free Press, It s not the be-all and end-all but it s part of the process Even with the wasps doing their jobs, the clear signs of the borer here mean these trees might not survive the next five years. According to the USDA FS Southern Research Station, parasitism helped control emerald ash borer populations, especially after their numbers naturally declined when fewer ash trees were available for them to feed on Comment: The Proposed Action must be rejected because it fails to respond to the Purpose & Need. In spite of your Purpose & Need goal to preserve local hydrologic function, the aquatics resources are in the list referred to as non key, secondary issues that should be dismissed. Is it possible to preserve local hydrologic function and ecological services while at the same time dismissing The effects of treatments and activities on water quality, aquatic: Acres of riparian management zone disturbed; number and miles of wetland crossings by temp roads; localized hydrology impacts. (page 15) Logging 6.2 square miles and constructing 12 miles of new road will inflict harm on local hydrologic function. Once again, your zeal to accumulate volume makes a consistent NEPA document impossible to write. Request for changes to be made to the final NEPA document: Decide which is most important on the Deer River District: volume or aquatic resource health. Then modify the EA accordingly. If you eliminate preserve local hydrologic function from the P&N you will have made your choice. 1.3 Response: We did analyze all secondary issues and presented the effects of alternatives on aquatic resources (EA Sec 3.4.3). The issues of proposed riparian management zone activities and wetland crossings by temp roads is expected to have no significant impacts on aquatic resources for reasons described in section Preserving local hydrologic function and ecological services is a purpose and need of this project and was analyzed for effects (EA Sec ). The alternatives were also analyzed on how well they met the purpose and need. Alternative B (the proposed action) best meets the purpose and need (EA pp 41, 42). The project purpose and need is not to provide volume but is to preserve local hydrologic function (see comment above). 2. Sierra Club G - 4

5 2.1 Comment: The Agency proposes group selection harvests with planting in order to promote ash stands that will be resilient enough to withstand the spread of EAB. How successful has this strategy been in the past? What kinds of forests has this strategy been used in? How did the Agency decide that the proposed alternative was the best, scientifically proven, course of action to take against the disease? Has this strategy been used in similar ecosystems with successful results? Are there alternative methods that have been used to protect ash stands from EAB, and what were the results? 2.1 Response: We have used the best available science in developing this project. Some of this science is being developed within the National Forest through partnership with the University of Minnesota and the Forest Service Northern Research Station. Researchers have been studying group selection harvesting plus planting in black ash stands on the Chippewa National Forest since 2011 (Sleasak et al 2014). The Chippewa National Forest incorporated published and unpublished information from these scientists when designing the Proposed Action. Early research results shows that some of the planted species are surviving better than others. While other harvest types were tested and the group selection harvest method has been shown to maintain the hydrology best. We will continue monitoring the results of this study and adjust our planting strategies to get the best survival and establishment in order to maintain forest cover on these sites. Natural resource managers in Wisconsin have been managing black ash stands since the 1970 s with varied results. Wisconsin, Michigan, and Minnesota have management guidelines that incorporate partial harvest (single tree and single tree combined with gaps) plus planting, seeding, and/or natural regeneration to increase species diversity in black ash stands (Project record, WI DNR 2014, MN DNR 2010, MI DNR 2012). There are alternative methods being researched to control EAB directly but we have not incorporated those into this proposal since researchers are still looking at the effectiveness of these treatments. Most of these treatments were applied to high value individual trees in more of a residential or urban community. Also we are not sure if the scale at which we would have to employ chemical and biological controls would be feasible or logistically possible in order to control EAB and preserve lowland hardwood forest. Research is being conducted to evaluate the use of insecticides, parasitoids, biological pathogens, regulatory control treatments, and resistance mechanisms of Asian ash species with potential to develop hybrids between Asian and North American ash species. Research is ongoing. As results of these studies become available and if they are effective, we will consider doing additional environmental analyses for those treatments in the future. 2.2 Comment: How many stands were dropped due to wetland accessibility? How many stands were dropped due to sensitive species considerations? Which species were thought could be affected? The Biological G - 5

6 Assessment (BA) and Biological Evaluation (BE) do not provide any information or evaluation as to how this decision was made. These issues need to be analyzed and disclosed. 2.2 Response: While reviewing all high risk ash stands seventy-seven stands were dropped due to wet access (Project Record). The BE of Sensitive Animal Species indicates (p. 9) that nest and post-fledging zones of sensitive raptor nests (i.e. red-shouldered hawk and northern goshawk) were avoided when selecting stands to be harvested. Annual bald eagle flights contribute nest location data which were considered in the design of this project. According to the project record, approximately 69 forest stands were removed from further consideration in the Ash Diversification EA due to the presence of red-shouldered hawk, northern goshawk, bald eagle, or great gray owl nests. This measure was due to the application of Forest Plan Standards and Guidelines S-WL-3, G-WL-13, G-WL-14, S-WL-8, G-WL-24, and G-WL-15.. Regarding sensitive plant species, the interdisciplinary (ID) team dropped 15 forest stands where their occurrence was equal to or a major contributing factor in addition to silvicultural or access issues. In another 31 stands, sensitive plant site(s) occur within stands but their presence was not the primary reason for dropping the stand. In 43 other stands dropped by the ID team, sensitive plant site(s) occur within 250 feet of the stands at varying distances. Collectively among all of these stands, 17 different species occur in dropped stands or within approximately 250 feet. Little goblin moonwort exists in 27 stands, Canada yew (21), white adder s-mouth orchid (17), bluntlobe grapefern (7), and northern burreed (7). The remaining species exist in 1 to 4 of the stands. 2.3 Comment: What exactly is enhanced elm seed and where does it come from? How has it been changed to be resistant to the disease? What are the risks associated with introducing it into the Chippewa National Forest? 2.3 Response: The Chippewa National Forest and Forest Service Researchers have been collaborating on an American elm restoration project since American elms from the Chippewa National Forest that have survived Dutch Elm Disease (DED) have been cross-pollinated with known DED-tolerant elms from the northeast U.S. in hopes of restoring American elm with DED-tolerant, cold-hardy, and site-adapted trees. Seed from this project are considered enhanced. American elm was historically a component of the ash stands on the Chippewa National Forest. The risk of not using enhanced elm seed is that the elm will continue to decrease on the landscape even more over time. There is still a risk using enhanced seed that these seedlings may not survive DED. 2.4 Comment: Any presumed positive effects of using woody biomass in the production of heat or electricity, including reducing national reliance on imported fossil fuels, is far outweighed by the value of the forest as a carbon sink. Therefore, the use of public lands to collect woody biomass for generating thermal and G - 6

7 electric energy should be discouraged. Biomass is a vital component to a healthy forest because it provides future nutrients to the soil and important habitat for wildlife. How much and what types of biomass does the Agency plan to harvest and which units will it come from? How will this removal of biomass affect wildlife in the area? This project is supposed to be about preventing the devastating effects of EAB, not about harvesting commercial wood products. The collection of woody biomass should not occur. 2.4 Response Management of ash stands in this project focuses on keeping forested stands forested, not on managing the emerald ash borer. All harvest treatments were designed to provide growing space for the next age class of trees, thereby facilitating increased species diversity and resilience in black ash stands. Although biomass harvest is not included in this project s Proposed Action if it were the only available means to remove some trees to make room for the introduction of other species there are mitigations identified in the forest plan and the MFRC Gold book (MFRC 2005 ) which would require leaving some woody debris for wildlife and other resource reasons. Management of ash stands in this project focuses on keeping forested stands forested, not on managing the emerald ash borer. All harvest treatments were designed to provide growing space for the next age class of trees, thereby facilitating increased species diversity and resilience in black ash stands. Although biomass harvest is not included in this project s Proposed Action if it were the only available means to remove some trees to make room for the introduction of other species there are mitigations identified in the forest plan and the MFRC Gold book (MFRC 2005 ) which would require leaving some woody debris for wildlife and other resource reasons. The end result and appearance would be the same based whatever utilization method is used. 2.5 Comment: This project proposes to build 12 miles of new roads. The Sierra Club is concerned with the impacts that these roads will have on the area. What are the cumulative effects on the Chippewa of building more roads? Why was this not evaluated in the EA? What is the timeline for decommissioning these roads? How will the impacts that these roads have on the forest change depending on how long they stay open. 2.5 Response: No new roads or changes to existing system roads are proposed by this project, with the closure of all the temporary roads (12 miles) there would be no cumulative effects due to roads. Alternative B proposes 12.3 (EA Errata) miles of temporary roads which would be needed to access stands, during frozen ground conditions only, and will be effectively closed when the project is completed. As stated above because of the nature of these winter only access roads they will be effectively closed as activities are completed on each segment. There is also a Forest Plan objectives, standards and guides that require temporary roads to be closed after use (O-TS-3, S-TS-3; G-TS-14, S-TS-2) Because the G - 7

8 project proposal would construct temporary roads during frozen ground conditions, little or no ground disturbance is expected. Temporary road and trail blocks will prevent use under non-frozen conditions. The temporary roads would occur in about 72 segments, and vary in length from less than 0.1 mile to about 0.6 miles in length. Effects of the temporary roads were identified in the EA for Wildlife ( P. 28), aquatics (P ), recreation (Sec ), Tribal gathering and traditional uses (Sec ), soils (Sec ). 2.6 Comment: The EA states that proposed roads will cross wetlands 42 times, and goes on to say that these roads may end up being located on poorly suited soils, resulting in an increased risk of soil erosion, rutting, compaction and effects to soil productivity (61). Will the roads be completely ripped up to remove the compacted soil layers? Will the slide slopes of soil be put back and properly reshaped to allow surface and subsurface water flow to be restored? Will culverts and drainage structures be removed and stream channels fully reconstructed? Will the original vegetation in the area be replanted? 2.6 Response: The 42-wetland crossings total 11,271 feet, with an average length of 225 feet. The narrow winter roads may require clearing of trees and brush, however the overall removal of wetland vegetation would remain minimal. Because the project proposal would construct temporary roads during frozen ground conditions, little or no ground disturbance or compaction is expected. Under frozen conditions, temporary roads and skid trails can occur in wetlands, if no fill is placed in the wetland. Because of the lack of ground disturbance and compaction, no rehabilitation will be needed. No drainage structures are required. If the temporary roads or skid trials thaw, use will be suspended until sufficiently refrozen. Temporary road and trail blocks will prevent use under non-frozen conditions. The area will naturally revegetate. 2.7 Comment: The EA states that there will be 178 acres of riparian management zone (RMZ) in near zone (within 100 feet of shoreline) where project activities will include harvesting. And 344 acres of RMZ within 200 lakes of shorelines will be disturbed due project activities including harvesting (21). Harvesting should not be taking place in riparian areas. These areas are too fragile. The EA states that harvesting can result in riparian areas becoming less effective as nutrient and sediment filters. Harvesting in riparian areas reduces the amount of woody debris that enters water resources which can harm aquatic organisms and their habitats. 2.7 Response: This project promotes forest plan desired conditions within RMZs to preserve and enhance riparian and hydrologic functions. The forest plan recognizes the benefits of long term proactive management and directs the Chippewa national forest to seek opportunities where appropriate. Long term benefits often come at the expense of increasing risks of short term impacts due to ground disturbance and exposure. G - 8

9 Alternative B was designed to incorporate proactive riparian management where stand prescriptions were compatible with the goals described in the Forest Plan for RMZ management. While posing a short term risk to water quality due to the proximity of the harvest activity to watercourses, activities that increase structural and species diversity or favor long lived tree species would have long term benefits to the water quality and the aquatic and terrestrial habitats that the RMZ is designed to protect. The components of the RMZ such as shading, large wood habitat source, nutrient inputs and stream bank composition are protected to a large extent by the near-zone RMZ. These components would be preserved through silvicultural prescriptions designed to enhance the RMZs function over the long term while limiting short term impacts to the RMZ components, erosion, and sedimentation by implementing forest plan protections, best management practices, project mitigations, and allowing harvest only during frozen ground. Harvest activities within the RMZ under the action alternative s are generally only permitted where prescriptions would increase within stand diversity and improve riparian functions. Probable benefits for treatments to the RMZ include: increase within stand diversity by creating light conditions on the forest floor light over a considerable portion of the stand that would allow for the establishment and advancement of other tree, shrub, and herbaceous species, protect existing within-stand tree species and age-class diversity, by retaining and protecting all nonash tree species in the treatment areas, and/or promote long-lived site suitable tree species in RMZ (i.e., red pine, white pine, tamarack, cedar, maple, basswood, oak, black spruce) this includes retaining all large diameter (20+ inches) long-lived conifer species (e.g., red pine, white pine, cedar, tamarack) in the RMZs.(PR -Aquatic Resources Report) Further reducing the expected short term disturbance is the observed existing diversity seen in aerial photographs that is greater in the fringes that are adjacent to lakes, stream, open water wetlands, and open flood plains. Portions found to have existing diversity or have low forest cover will not have tree cutting, however further diversity planting would still be desirable. 2.8 Comment: It is the responsibility of the Agency to protect sensitive species so that their populations can once again flourish. Decreasing sensitive species habitat only exacerbates the problem. The EA states: for those species that do use black ash as part of their habitat, such as northern goshawk, red-shouldered hawk, and four-toed salamander, the activities proposed by Alternative B could have some negative effects due to the proposed timber harvest. The potential for some of these effects to occur would be reduced if surveys for nesting red-shouldered hawks and northern goshawks would be conducted around the proposed activity stands. Forest Plan Standards and Guidelines, designed to minimize impacts to these two species, could then be applied as warranted (29). Why have surveys not yet been conducted? When will they be completed? How and when will the public be notified as to how survey results change project design? 2.8 Response: G - 9

10 As indicated in the EA (p. 29) and BE of Sensitive Animal Species (pp 3-4, 23): Black ash does not serve as habitat for many of the species listed as sensitive on CNF. But for those species that do use black ash as part of their habitat, such as northern goshawk, red-shouldered hawk, and four-toed salamander, the activities proposed by Alternative B could have some negative effects due to the proposed timber harvest. The potential for some of these effects to occur would be reduced if surveys for nesting redshouldered hawks and northern goshawks would be conducted around the proposed activity stands. Forest Plan Standards and Guidelines, designed to minimize impacts to these two species, could then be applied as warranted. These Standards and Guidelines are elucidated in the BE (pp. 14, 17). The BE (p. 9) addresses project surveys: To date, no surveys for sensitive animal species have been conducted specific to the Ash Diversification project. Project surveys may be completed in the future, but there is no assurance of that, due to the desire to move along timely with project activities, given the sense that the advent of EAB may be imminent. All currently existing survey information indicating sensitive species presence was considered in the design of this project. Nest and post-fledging zones of sensitive raptor nests (i.e. red-shouldered hawk and northern goshawk) were avoided when selecting stands to be harvested. Hence, existing survey data proximate to proposed activities conducted relative to other projects was used to design the Ash Diversification project to minimize potential impacts to sensitive species. Project surveys specific to the Ash Diversification project may or may not be completed prior to project implementation because the goal of this project is to diversify these stands to maintain lowland Forest cover before EAB arrives. As specified in the BE (pp. 14, 17), if any new nest sites for red-shouldered hawks or northern goshawks are discovered, either by project surveys or through the course of project implementation, Forest Plan Standards and Guidelines G-WL-13, G-WL-14, S-WL-8, and G-WL-24) would be employed. These measures are designed to reduce the direct effects of activities on nesting goshawks and red-shouldered hawks through the maintenance of high quality habitat conditions and canopy closure, as well as restrict activities to the non-nesting season. There are no additional plans to notify the public regarding how survey results change the project design. 2.9 Comment: Lynx denning habitat requires there to be an abundance of coarse woody debris to provide escape and thermal cover for kittens. Harvesting of biomass could affect potential future lynx denning habitat; no biomass harvesting should occur under this project. Lynx need forest connectivity - no temporary roads should be built. Temporary roads will affect lynx the same as permanent roads. Increases in snow compacted routes adversely affect lynx by allowing bobcat and coyotes to access areas of deep snow and compete with lynx. Instead of adding roads to the system, more roads need to be decommissioned. Why does the BA contain no information on LAU road density? This information needs to be included. How do proposed temporary roads change LAU road density? 2.9 Response: G - 10

11 As stated in the EA (p. 28), supported by analysis in the BA (pp. 8-12), the activities proposed by Alternative B are Not likely to adversely affect Canada lynx or its habitat. The rationale is that no changes to vegetation are proposed in lynx habitat, and temporary roads would be closed upon project completion. Black ash forest is not considered Canada lynx habitat. The project proposals will not affect denning habitat. This project does not propose any new system roads; no changes to system roads are proposed by this project. Alternative B would involve about 12.6 miles of temporary roads to be built; these would be effectively closed when the project is completed. The temporary roads would occur in about 72 segments, and vary in length from less than 0.1 mile to about 0.6 miles long. They would be scattered across CNF and occur in numerous LAU s. On 10/3/2015 the U.S. Fish and Wildlife Service concurred with the findings of the BA (project record). In that concurrence, they state: Proposed harvests will not occur in habitat typically used by lynx no new system roads are being proposed and the temp roads will be effectively closed after use, such that the Forest will adhere to all lynx indicators. The proposed Project will also comply with all relevant Forest Plan objectives, standards, and guidelines with the exception of G-WL-8 (maintain road densities at or below 2 miles per square mile). While the BA indicated that many LAU s are already above this road density threshold, the Project is not creating any new system roads, so will not be further out of compliance with this guideline. 3.1 Comment: 3. MN DNR On page 25 under alternative B, it states the tree species that are going to be planted on the treatment sites to diversify ash stands. In that list are hackberry, swamp white oak, silver maple, cottonwood and boxelder. It would be useful to explain the longevity for these species for reforestation, since they are not typical dominate cover types in the plant community or area. 3.1 Response: The list of tree species for planting is meant to be an inclusive list of species that would be suitable in and tolerant of wetter sites. Multiple species would be planted in every stand to increase the likelihood of success in establishing non-ash species. The species you mention currently occur on the Chippewa National Forest, although not in large amounts. Longevity (years) of these species: Hackberry: 20 Swamp white oak: Silver maple: 130 Cottonwood: 25 Boxelder: G - 11

12 4.1 Comment 4 Jeffrey Latzka On page 9 of the EA it states, that 25,111 acres of (black) ash type forest or 4% of exist on CNF. Of that total 7300 acres are of ash stands. Mitigation efforts would be done on 3340 acres or 13% of all ash stands considered high risk for EAB infestation and include a high priority for treatment. On page 18, it described that single tree selection with about 1/3 basal area would be done on 630 acres of pure stands. Group selection with ¼ to ¾ gaps would be cut in about 2615 acres of pure ash. Alternative species would be planted or seeded on those acres. Where group selection with the gaps happens not more than 20% of the stand would be cut or removed. That is about 500 acres or less of the total 2615 acres. 4.1 Response: Thank you for your comments. You are correct on the acres of proposed activities and acres of ash forest type on the Chippewa National Forest. 4.2 Comment: Accordingly, the EA states that harvesting would be done during the winter when the ground is frozen. The current seven days forecast for northern Minnesota calls for a real cool down with freezing temperatures to harden those soils and make ice before heavy snows fall which could insulate the ground. With good frozen soil and water conditions it would be good to have a foot of snow at least to soften the effects of skidders or other heavy equipment. Building of temporary roads should take all precautionary measure to protect the integrity of the 42 wetlands that may be affect in this mitigation process of these ash forests. 4.2 Response: Thank-you for your comment. The harvest will all be done on frozen ground and the timber sale administrator or contract officer will be watching conditions to stay within that prescription. All temporary roads will be also only done on frozen ground so as to not disturb the wetlands. 4.3 Comment: Appendix B lists 230 stands that will have some kind of harvest intrusion. Using Appendix A maps, and cross referencing them on color coded GIS maps for Vegetative communities and Age class types; I sampled 500+ acres of large stands sites and all showed mature and one stand site (3/4180/3, 73 acres was illustrated old. Contacting MNDNR Forestry, It was said that.this is costly and marketing would save some costs. 4.3 Response: G - 12

13 We agree that this project will be costly and our implementation teams will be working on ways to market and fund the post-harvest activities. While we considered economics in this project, it was not a primary driver of our purpose and need. We are planning that several products could be sold from this project and will be working a strategies to market this wood the best we can. Grants, stewardship projects and other partnerships will be pursued to make this project successful. 4.4 Comment: According to DNR Forestry the EAB is now mostly in SE Minnesota..I hope and pray that EAB finds Minnesota a marginal habitat and mitigations are sound. 4.4 Response: We also hope that EAB finds Minnesota marginal habitat. 5.1 Comment: 5 LLBO District 1 representative Thanks you for the information. I have reviewed the information and thought it best I seek the opinion of our DRM staff.they may or may not be submitting suggestions on my behalf. 5.1 Response: Thank you for your comments and we will watch for comments from the DRM staff. 6.1 Comment: 6 State Historic Preservation Society Thank you and we look forward to consulting with you under Section 106 of the NHPA. 6.1 Response: We look forward to continued work with you. 7.1 Comment: 7 National Park Service Does not have objection standing The potential impacts from the Group Selection harvesting operations along the approximate 500' of NCT within Stand 5/157/12 have been generally well addressed and mitigated as a function of the plan and through the Forest's response to Scoping (Appendix D, 2-1). However, per the Forest's response to the scoping comments that "Temporary damage and disruption to the North Country Trail shall be kept to minimum. Any damage to the trail will be repaired", I would request that a time standard be assigned to this statement to define how promptly any damage would be repaired. I would also request that the standard mitigations applied to the NCT (G-Rec-2, for example) include additional guidance in specifying G - 13

14 that if the Trail is open to the public during harvesting operations, it will, as a minimum, remain navigable and free of major obstructions or obstacles. 7.1 Response: Language in the timber sale contract provides that the trail is to be protected, kept open and any debris immediately removed. Damage is repaired the same day. Signing will be posted on either end of the section of trail that is affected, warning users of timbering activity. 7.2 Comment: In lieu of having specific information to consider, I request that any post-harvest treatments within any stand that the NCT passes through (currently limited to stand 5/157/12) incorporate mitigation measures to establish a protected corridor where no scarification, furrowing, or other similar ground disturbance shall be allowed. The width of the protected corridor should be the minimum distance necessary to provide that the trail tread is unaffected and that ground disturbance will not be visible to hikers traveling along the Trail once vegetation has become re-established. If operational considerations make this request unfeasible to implement, an alternative would be for the Forest to commit to repairing and rehabilitating any portion of the Trail impacted by post-harvest/pre-planting treatments within one month after the treatment has been completed. 7.2 Response: All tree cutting would be done under frozen conditions because of access and resource protection. No scarification, furrowing or other ground disturbance is planned in any ash stand in this project. If postharvest treatments (e.g. planting) impact the NCT, this trail would be rehabilitated. G - 14